WEBSITE PRIVACY POLICY

ICAM S.r.l. offers this website to its users and customers in order to provide free, simple and clear information about its business activities. Our purpose is to provide up-to-date information which is as complete and accurate as possible. Our Company cannot be held responsible in any way for the accuracy, quality or level of completeness of the information provided within the site itself. We are therefore not liable for any material or immaterial damage deriving from the use or non-use of the information provided, or from the use of incorrect or incomplete information. The information provided in this website is not directly binding and must always be confirmed by email or in other written form by the site owner.

Information regarding the processing of personal data

ICAM S.r.l. would like to inform you that this page describes the way the company website (“Website”) manages the personal data of the visitors and users who consult it. In compliance with Italian and European legislation on the protection of personal data (EU Regulation 2016/679), this information is made available to anyone who interacts with the web services of the Website and does not therefore apply to any information collected via any channels other than this website. Accordingly it is not applicable to the data processing carried out through ICAM S.r.l. partner sites, to which the user can gain access via a link on this website. For further details about this data processing it is necessary to contact the relevant Data Controllers of each website.

By personal data we mean all the information relating to the user that allows us to identify them, such as name, surname, contact details, telephone number, email address and any further information regarding the user’s visit to our website. We may also collect your personal data when you contact us by phone, send us an email, make a request for assistance (Service Requests) or use the social network plug-ins in use on the Website. By using this Website or browsing its pages, ICAM S.r.l. will process visitor and user data to: - provide product information;

- participate in initiatives organised by us via the Website, for example events, calls for ideas and so on; - provide the necessary assistance for the Help Desk and Service Requests as well as support and technical assistance through the use of tickets opened by the user/distributor/dealer;

- check the level of user/customer satisfaction;

- check the necessary automatic collection of data regarding any visitor interaction with the Website;

- analyse aggregated data regarding visitor and user behaviour or use aggregated data to analyse the way the Website behaves;

- match the requests for subscription to the newsletter service on selected topics of interest (corporate communication on events, initiatives, recurring events and new products or case studies);

- manage any CVs sent by user via the “Work with us” page (if you send us your CV for an active vacancy, we will use your data exclusively for this purpose and this CV will be kept for a maximum period of twelve months, after which it will be deleted. At this point you can of course send us a new, updated version, if you wish);

- prevent or identify fraudulent activies or malicious use that could damage the Website.

We will only process your personal data if we have a legal basis to do so. The legal basis will depend on the reasons for which we have collected and must use your personal data. These reasons may derive from the necessity to provide feedback to your requests (contractual or pre-contractual purposes), to comply with certain legal and/or regulatory requirements or to pursue the legitimate interests of the Data Controller; in any other cases, however, your consent may be necessary, for example for direct marketing and in order to send business communication material or for profiling activities in addition to the cookies issued by our website.

The processing of any speculative CVs, which needs to be carried out to evaluate candidates with regard to any possible vacancies at ICAM S.r.l., complies with regulations because it is expressly authorized by law, which specifies that in this case the consent of the interested person is not necessary. You are free to decide whether to send us your CV, but should you decide not to, we will be unable to evaluate your suitability for any position at ICAM S.r.l.

Where do we obtain your data and how do we get it? (including the consequences of any possible refusal to communicate such data)

Your data may be collected online when you browse the Website or send emails and faxes or make phone calls to the numbers indicated; more specifically personal data, such as your email address and where requested your telephone number, might be necessary for the aforementioned purposes, for example, providing a reply to the request you sent us. If you choose not to supply the necessary data in order to satisfy your request, it may make it impossible for us to provide you with a suitable answer or provide any other services. Depending on the specific case, from time to time as necessary, you will be informed of the mandatory or optional nature of the necessity to provide personal data, for example to carry out a specific request. This compulsory or optional nature of communicating data will be indicated via a notice or the insertion of an asterik (*) next to the obligatory fields. Finally, please note that any failure to provide optional personal data will not result in any obligation or disadvantage.

Who do we communicate your data to?

In order to use our online services, in addition to fulfilling certain legal and/or regulatory requirements or in order to fulfill the legitimate interests of ICAM S.r.l., your data may be disclosed:

- to our employees and internal internal associates (for example associates and employees who are specifically authorized for data processing and to our national and international sales network);

- to third party companies, connected to ICAM via contract, or to other parties that carry out outsourced activities and services on behalf of the Data Controller (suppliers of third party technical services such as hosting providers, communication agencies, web platform maintenance and development providers, development service providers, technological platform providers and managers etc), and are appointed, where necessary, as external managers for the processing of personal data;

- to third parties for whom this is necessary and indispensable (or in any case practical) in order to carry out ICAM S.r.l.’s business operations.

Social media: we may use social media plug-ins on our website. As a result the data collected will be shared with the social media service and possibly shared on your social media profile. Please refer to the relevant privacy statement of these third-party social media providers to learn more about how this procedure works.

In any case your personal data will not be disclosed, unless this data is required by the forces of law, by the Police, the Judical Authority or by other information or secutiry forces or other public bodies for the purposes of national defence or security or for the prevention, detection or repression of criminal acts.

Who do we transfer your data to?

The management and storage of your personal data will take place in Italy and it will not be transferred out of or otherwise leave the European Union. Our servers are currently based in Italy. However, it should be understood that if we deem it necessary, we retain the right to change the server location within Italy and/or the European Union and/or any non-EU countries. Should this occur though, we will ensure that henceforth the transfer of data outside the EU will take place in accordance with the applicable legal regulations, which stipulate agreements guaranteeing an adquate level of protection and/or adopting the standard contractual clauses provided for by the European Commission or with any other requirement in compliance with the applicable Italian and European legislation in force at that time.

For marketing activities we use tools provided by Google and/or other suppliers located outside the EU, who nevertheless guarantee that data processing is carried out in compliance with all applicable legislation.

How long do we keep your data?

The data collected by the Website during normal operation is used exclusively for some of the purposed indicated above and is only kept for the time strictly necessary to carry out our activities.

We will not store any data for longer than is necessary to fulfill the purpose for which it was collected. To determine the appropriate storage period, we take into consideration the quantity, nature and sensitivity of the personal data in question, the purpose for which we must process it and whether we can achieve these goals by any other means.

The data collected by the Website will therefore be kept for the time period necessary to reply to requests and then when terminated will continue to be kept only in order to fulfill any possible contractual, pre-contractual or related obligations arising from them; unless you have not given explicit consent with regard to some of the services offered, because in this case processing will continue until consent is revoked.

How do we process your data and how do we comply with data protection regulations?

Your personal data is processed electronically and automatically strictly for the time necessary to achieve the purposes indicated above. Specific technical and organizational security measures are observed to prevent any data loss and illicit or incorrect use or unauthorized access to this data.

We have adopted a series of technical and organizational security measures to ensure the confidentiality, integrity and availability of your data.

Data processing is carried out correctly and according to legal requirements in compliance with the principles of minimization.

How do we guarantee your rights?

ICAM S.r.l. would like to point out that, according to new European legislation on data processing, under certain circumstances you have the right:

1) to ask us for confirmation of the existence of any data processing regarding your personal data and if that should be the case, you have the right to obtain access to this data and all the information relating to the processing procedure;

2) to obtain the modification and correction of any inaccurate personal data and to complete any incomplete personal data by providing us with an additional declaration;

3) to achieve the cancellation of data if:

- the data is no longer necessary with regard to the purposes for which it was collected or processed,

- the data was processed unlawfully,

- the data must be deleted in order to fulfil a legal obligation,

- you have revoked your consent,

- You ask to stop processing your personal data;

4) to obtain limitations on data processing (and therefore to suspend it) when one of the following hypothetical situations occurs;

- if the accuracy of the personal data is contested, for the period necessary for us to verify the level of accuracy;

- if the processing is illegal and you decline the deletion of your personal data and instead request limiting its use;

- if the personal data is necessary for the assessment or exercise of legal rights in a judiciary court for the interested party;

- if the interested party has opposed the data processing, pending verification of the possible prevalence of our legitimate reasons with respect to yours;

5) to request the transfer of your personal information, in either an electronical or structured form, to another person (“data portability”); 6) to object in part or entirely to the data processing procedures;

7) to revoke, at any time, the consent given (in these cases withdrawal of consent does not affect the lawfulness of the data processing based on the consent given before it was revoked);

8) to propose a complaint to the Guarantor for the protection of personal data (for further information please send a request to the website www.garanteprivacy.it).

If you wish to exercise any of these rights, please send a request to the following email address: privacy@icamonline.eu.

The right to oppose the processing of personal data for marketing purposes can be exercised individually both via the automated contact methods (email, SMS or other tools used by the Data Controller) or by more traditional methods (postal mail or telephone). This right may be exercised in part of entirely (e.g. only using postal mail or telephone or by opposing only the sending of promotional communication via automated tools such as emails, text messages) by writing to privacy@icamonline.eu.

Changes and updates to this Privacy Policy

ICAM S.r.l. will be responsible for modifying and updating in part or entirely the Privacy Policy to be found on this Website, in particular with regard to any changes in the law or regulations that govern this matter and protect the rights of users. Following changes and updates to the Privacy Policy of the Website, users of our services whose data we already hold will be notified by email and in any case this information will be made available on our Home Page as soon as it is adopted by the company. We therefore ask you to access this section regularly in order to be able to consult the most recent and up-to-date version of our Privacy Policy.

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